Code of Conduct

A community for responsible leather

Our LEATHERPRINT® is our ongoing commitment to conscientiousness towards the environment, society and economic activity.

It brings together our holistic approach to sustainability so we can share them, build on them, and use them to guide us in manufacturing. It is an opportunity to innovate. It shows us how to produce better leathers that significantly impact society and the economy but have as small a footprint on the environment as possible.

Our Leather Working Group (LWG) accreditation is another step towards greater holistic sustainability in our day-to-day practices. LWG, being a global multi-stakeholder community committed to building a sustainable future with responsible leather, fits beautifully with our LEATHERPRINT® approach, driving industry best practices and positive social and environmental change for responsible leather production.

1. Our Society 

Equal Employment Opportunity and Non-Harassment Policy

Mossop-Western Leathers is committed to employment equity and a policy of no harassment. All employees, regardless of position or title, will be subject to disciplinary action, which could result in dismissal, should Mossop-Western Leathers determine that an employee has failed to comply fully with this policy.

Mossop-Western Leathers Will Not Tolerate Discrimination

Mossop-Western Leathers will not tolerate any discrimination, directly or indirectly, on any arbitrary grounds, including but not limited to race, gender, sex, ethnic or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, political opinion, culture, language, marital status or family responsibility. Mossop-Western Leathers's policy is to recruit, hire, compensate, train, promote, transfer, terminate, and administer any personnel actions without discriminating. However, following the Employment Equity Act, 55 of 1998, it is not unfair discrimination to promote affirmative action consistent with the Act or to prefer or exclude any person based on an inherent job requirement.
Mossop-Western Leathers will not condone or tolerate the discrimination or harassment of its employees by their co-workers, managers, customers, vendors, suppliers, third parties, or any individual under Its control.

Affirmative Action Measures

Affirmative action measures ensure that suitable, qualified employees from designated groups have equal employment opportunities and are equitably represented in all occupational categories and levels within the company. Mossop-Western Leathers is committed to eliminating barriers that may harm designated groups, promoting diversity and retaining, developing and training all employees.

Affirmative action will be based on merit and the potential of the employee.

Mossop-Western Leathers Will Not Tolerate Any Form Of Harassment

Mossop-Western Leathers also prohibits any harassment, directly or indirectly, on any arbitrary grounds, including but not limited to race, gender, sex, ethnic or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, political opinion, culture, language, marital status or family responsibility.

Examples of unacceptable conduct include, but are not limited to, the following:

• epithets, slurs, jokes, negative stereotyping, derogatory comments, threats or intimidation, or any similar verbal or physical conduct that denigrates or shows hostility or aversion towards an individual because of race, gender, sex, ethnic, or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, political opinion, culture, language, marital status or family responsibility;
• display or circulation in the workplace of written or graphic material that denigrates or shows hostility or aversion towards an individual or group (including through email), such as derogatory posters, photographs, cartoons, drawings, or gestures; or
• physical conduct, such as assault, unwanted touching, or blocking normal movement based on race, gender, sex, ethnic or social origin, colour, sexual orientation, age, disability, religion, conscience, belief, political opinion, culture, language, marital status or family responsibility.

All Mossop-Western Leathers employees, particularly managers, are responsible for keeping the environment free of harassment.

Mossop-Western Leathers Will Not Tolerate Sexual Harassment

Sexual harassment is also prohibited. Sexual harassment includes any unwelcome or unwanted conduct of a sexual nature (verbal, written, or physical) when

1. Submission to such conduct is made a term or condition of a person’s employment, either explicitly or implicitly;
2. Submission to or rejection of this conduct by an individual is used as a factor in decisions affecting hiring, evaluation, promotion, or any other aspect of employment; or
3. This conduct has the purpose or effect of substantially interfering with an individual’s employment or creating an intimidating, hostile, or offensive work environment.

The unwanted nature of sexual harassment distinguishes it from behaviour that is welcome and mutual. Sexual attention becomes sexual harassment if:

1. The behaviour is persisted, although a single incident of harassment can constitute sexual harassment; and
2. The recipient has made it clear that the behaviour is considered offensive; and
3. The perpetrator should have known that the behaviour was unacceptable.

It is impermissible for any employee, contractor or agent to sexually harass another, regardless of the sex of either party. Sexual harassment is inappropriate and contrary to Mossop-Western Leathers policies, whether it involves co-worker harassment, harassment by a manager, or harassment by persons doing business with or for Mossop-Western Leathers (vendors, suppliers, customers, etc.).

Examples of unacceptable conduct include, but are not limited to, the following:

• threats or promises of benefits in exchange for sexual favours or implying that things will go smoothly in exchange for sexual favours;
• unwanted sexual jokes or flirtations, or obscene comments or gestures, or derogatory comments, slurs, or epithets;
• unwanted sexual advances or propositions, such as making a “pass” at another employee, offering to give an employee a massage, or making or threatening reprisals after a negative response to sexual advances;
• negative stereotyping based on one’s gender;
• graphic or verbal commentary of a sexual nature or abuse about an individual’s body, dress, sexual prowess, sexual deficiencies, or any sexual nature or the use of sexually degrading words to describe an individual or suggestive or abusive letters, notes, messages,, or invitations;
• unwanted or suggestive leering, whistling, pinching, or insulting;
• physical conduct, such as unwanted or suggestive touching, assaults, or impeding or blocking movements; or
• the display or circulation in the workplace of sexually suggestive words, jokes, objects, posters, cartoons, or pictures (including through e-mail), including nude or sexually suggestive photographs. 

These behaviours are unacceptable at Mossop-Western leather offices, in other work settings, such as business trips, and at business-related social events. All Mossop-Western Leathers employees, particularly managers, are responsible for keeping the environment free of harassment.

Reporting Discrimination

Mossop-Western Leathers strives to promote a climate where harassment victims will not fear reprisals or feel that their grievances are ignored or trivialised. Mossop Western Leathers must be made aware of discrimination and harassment before it can act to prevent or stop it. Mossop-Western Leathers cannot take corrective action unless it knows a problem exists. Any incident or situation you believe involves prohibited discrimination or harassment by any employee or individual must be reported immediately.

A report of discrimination or harassment should be made in person or in writing to the Human Resources office.

Suppose you conclude or otherwise feel that reporting to human resources is inappropriate or uncomfortable. In that case, you may report it to any other Senior Manager with whom you feel comfortable. It is entirely within an employee’s discretion as to which individuals to approach with concern or complaints of discrimination or harassment. 

We strongly recommend that an employee firmly and promptly notify the offender that their behaviour is unwelcome, but such notification is not required. Any manager or member of management who becomes aware of any possible discrimination or harassment should immediately advise Human Resources, regardless of whether the complaining employee wants the manager to do so.

Suppose the company becomes aware of a complaint of discrimination or harassment. In that case, Mossop-Western Leathers will investigate and, if appropriate, take prompt remedial action. For this reason, if a complaint of discrimination or harassment is brought to the company’s attention, Mossop-Western Leathers will investigate, regardless of whether the complaining employee wants the company to do so.

Mossop-Western Leathers will promptly and thoroughly investigate the facts and circumstances of any claim of discrimination or harassment. 

Mossop-Western Leathers will ensure that grievances about sexual harassment are investigated and handled in a manner that ensures that the identities of the persons involved are kept confidential. Only appropriate members of management, the aggrieved person, their representative, the alleged perpetrator, witnesses and interpreter, if required, will be present in the disciplinary inquiry.

Workforce profile and total remuneration (EEA4) 

The objective of the remuneration mapping exercise is to collect information for the assessment of the remuneration gap between the highest-paid and lowest-paid employees and, at the same time, to assess inequalities in remuneration regarding race and gender in the various occupational levels to achieve the founding principles of the Constitution of South Africa 1996 in terms of fairness and equality.

The remuneration mapping measures the Remuneration (i.e., fixed and variable remuneration) and then links this data to the employees reflected in the workplace profile, EEA2, for the reporting period concerned across all occupational levels for comparative purposes. 

Mossop-Western Leathers requires that the following anchors will be measured. The EEA 4 will reflect the employee's remuneration with the highest total remuneration (i.e. fixed/guaranteed and variable remuneration) for each occupational level in terms of population group and gender. Where applicable, information must be provided for both males and females for Africans, Coloureds, Indians, Whites and Foreign Nationals.

The EEA 4 will reflect the employee's remuneration with the lowest total remuneration (i.e. fixed/guaranteed and variable remuneration) for the lowest occupational level in your organisation regarding population group and gender. Where applicable, information must be provided for both males and females for Africans, Coloureds, Indians, Whites and Foreign Nationals. The EEA 4 will reflect the average/ mean remuneration, the median remuneration and the remuneration gap as required in Section E of the EEA4 Form.

Options to resolve the problem of Sexual Harassment

Mossop-Western Leathers will attempt to resolve an allegation of sexual harassment in a sensitive, efficient and effective manner. Employees have two options to fix a problem relating to sexual harassment. Either an attempt can be made to resolve the issue informally, or a formal procedure can be embarked upon. The employee is under no duress to accept one or other option.

Informal Procedure

It may be sufficient for the employee concerned to have an opportunity where she/he can explain to the person engaging in the unwanted conduct that the behaviour in question is not welcome, that it offends or makes them uncomfortable, and that it interferes with their work.

Suppose the informal approach has not provided a satisfactory outcome. If the case is severe or the conduct continues, it may be more appropriate to embark upon a formal procedure.

Formal procedure

Where the aggrieved employee has chosen a formal procedure:

1. A grievance should be lodged with Human resources. Your report should be as detailed as possible, including the names of individuals involved, the names of any witnesses, direct quotations when language is relevant, and any documentary evidence (notes, pictures, cartoons, etc.).
2. The grievance will be dealt with expeditiously.
3. The grievance will be investigated, and disciplinary action will be taken against employees at any level who engage in harassment up to and including dismissal. Any manager who knows about the harassment and discrimination and takes no action to stop it may also be disciplined. Remedial action may also be taken. This includes counselling, changes in work assignments, or other measures designed to prevent future misconduct.

Criminal and Civil charges

A victim of sexual assault has the right to press separate criminal and civil charges against an alleged perpetrator, and the legal rights of the victim are in no way limited by this policy.

Dispute resolution

Should a complaint of alleged sexual harassment not be satisfactorily resolved by the internal procedures set out above, either party may, within 30 days of the dispute having arisen, refer the matter to the CCMA for conciliation. Should the dispute remain unresolved, either party may refer the dispute to the Labour Court within 30 days of receipt of the certificate issued by the commissioner.

No Retaliation for Complaining of Discrimination or Harassment
Under no circumstances will an employee’s job status, security, working conditions, or relationship with Mossop-Western Leathers be adversely affected because a good faith report of discrimination or harassment is made or someone is involved in investigating such. Mossop-Western Leathers policy strictly prohibits subjecting an individual to any form of discipline or retaliation for reporting any incident or situation of discrimination or harassment, pursuing any claim of discrimination or harassment, or otherwise participating or cooperating in any investigation of a complaint of discrimination or harassment. Retaliation is a severe violation of this policy, and any retaliation also should be reported immediately. Any person found to have retaliated against another individual for reporting discrimination or harassment or otherwise participating in an investigation will be subject to disciplinary action, which could result in dismissal. Any individual who intentionally makes a false claim of discrimination or harassment will be subject to disciplinary action, which could result in dismissal.

HIV/AIDS Policy

Introduction

The company is aware of the far-reaching socio-economic and human rights implications that the HIV/Aids epidemic is having on all South Africans.  Unlike other life-threatening chronic illnesses, HIV/AIDS deals with contentious issues such as sex, sexuality, race, religion and drug use.

Ignorance and disbelief about the epidemic can lead to myths and misconceptions concerning HIV/AIDS, which in turn may result in infected individuals being excluded by society and exposed to victimisation at the workplace.  All these factors hamper preventative measures and effective management of the disease.

The company acknowledges its role in fostering a supportive, open and non-discriminatory employment environment. It seeks to minimise, as far as possible, the impact of the disease in the workplace.  Examples are employee absenteeism and morale, loss of productivity and profitability.

An essential component in successfully achieving the principle outlined in this policy is the understanding and cooperation of all employees.

As a working document, this policy will continually be reviewed to incorporate the latest developments that impact HIV/AIDS issues within the workplace.

The Policy

The aim of this policy is to:

• Demonstrate the Company’s commitment to addressing the impact that HIV/AIDS has in the workplace.
• Implement mechanisms that, in cooperation with employees, aid in preventing the spread of HIV.
• Eliminate the practice of unfair discrimination against HIV/AIDS-infected employees, including job applicants. 
• To achieve these objectives, this policy provides a framework whereby:-
• HIV/AIDS employment policies are addressed and communicated to employees.
• Awareness is created amongst employees about their rights and duties in terms of current legislation relating to HIV/AIDS.
• Expected standards of behaviour by all employees, including management, are set out, grievance procedures are made available, and measures to deal with deviations from such standards are appropriately taken.
• HIV/AIDS programs are outlined and implemented within the organisation occasionally.
• Communication procedures on HIV/AIDS issues are set out.
• Details of employee assistance are furnished.

This policy has been formulated per the guidelines in the Department of Labour’s Code of Good Practice: Key aspects of HIV/AIDS and employment, gazette notice R.1298 of 2000 and existing company practices and policies.

Employment Policies of the Company

Promotion of non-discriminatory workplace

The company will not unfairly discriminate against employees or job applicants inflicted with HIV/AIDS and will adopt fair labour practices.  No employee of the company, including prospective employees, shall be discriminated against based on their HIV status alone with regards to:

• Recruitment procedures, advertising and selection criteria.
• Appointments
• Job classification or grading
• Remuneration, employment benefits and terms and conditions of employment
• Employee assistance programs
• Job assignments
• Workplace and facilities
• Occupational health and safety
• Training and development
• Performance Evaluation systems
• Promotion, transfer and demotion
• Disciplinary measures
• Termination of service
• Performance management and procedures relating to incapacity and dismissal

Performance management of HIV/AIDS employees will be in accordance with the company's current policies.  Some examples of factors that will be taken into account in monitoring an infected employee’s service are:

• The ability to continue working satisfactorily in their current position and whether it is possible to transfer the employee to a position which can accommodate them in light of their current health status, providing that an alternative position is available.
• The possibility that continued employment is against the employee’s interest. An example is that the illness is accelerated or exacerbated.

Grounds for dismissal due to incapacity and poor work performance will only be made after a complete health status assessment.  Some areas that an Employer is entitled to investigate are:

• The nature and extent of the employee's incapacity
• The extent and degree to which an employee is unable to perform.
• The likelihood of an employee’s improvement.
• The size of an effect on the employer’s operations.
• The company should not unfairly discriminate and should protect employees against arbitrary dismissals.

Some examples, which are deemed to be unfair labour practices, are:

• Where an employer unfairly discriminates against the employee on the grounds of an employee’s health status.
• Where there is unfair conduct on the employer's part in promoting, demoting, providing training opportunities or supplying benefits to an employee.

Employees are, therefore, protected from discrimination and dismissal based on their HIV status.

HIV testing, disclosure and confidentiality

Employees will only be tested where allowed in terms of applicable legislation.  Medical testing is defined “as any test, question, enquiry or other means designed to ascertain or which enables the employer to ascertain, whether an employee has any medical conditions”.

An employer may only carry out medical testing if:-

• It is justifiable in the light of medical facts, employment conditions, social policy, the fair distribution of employee benefits or the inherent job requirement.

2. Confidentiality and disclosure

An employee is entitled to voluntarily disclose their HIV status to employees of the company, including Management.  If an infected employee discloses their status, the information will not be disclosed unless the infected person's written consent is first obtained.  If the infected employee cannot furnish written consent, alternative arrangements will be made with the employee concerned.

Employee benefits

The company will not unfairly discriminate concerning employee benefits.
Employees should know that a medical scheme cannot discriminate against someone based on their health status.  Accordingly, HIV/AIDS-infected persons are entitled to medical aid membership.  Employees are requested to contact the medical scheme’s administrator of the Company’s healthcare consultant for more information on HIV/AIDS benefits and programmes currently offered by the medical scheme.

Current legislation

Legislation currently applicable to HIV/AIDS and surrounding issues within the workplace has been summarised for the benefit of the employees.

South African constitution

Regarding the Bill of Rights in our Constitution, each person has a right to equality and non-discrimination, privacy (which includes confidentiality) and fair labour practices.  However, these rights may be limited in certain circumstances.  An example is when the Labour Court authorises an employer to carry out HIV testing on its employees or job applicants due to the inherent requirement of the job.  In this instance, the rights of an individual may be limited based on reasonableness relevant to a particular circumstance.

Sick Leave

Employees with HIV/AIDS are, similarly to non-infected employees, entitled to sick leave.

Safe working environment

The company will provide and maintain, as far as is reasonably practical, a safe working environment without risk to the health of its employees.
Employees should take note of the following basic principles of infection control.

• When giving first aid, avoid any contact with blood or other body fluids. This is done by covering any cuts or sores with waterproof plasters and wearing plastic or latex gloves.  If no gloves are available, the hands can be covered with plastic bags tied around the wrists.  If blood does get onto the skin, it must be washed off in hot, soapy water as soon as possible.
• Employees should notify cleaning staff of blood spills in the workplace. Blood spills on the floor or other surfaces should be treated with disinfectant before being wiped with absorbent paper.

Compensation for occupational injuries and disease act

Suppose an employee becomes HIV infected during the course and scope of their employment. In that case, they will be entitled to compensation, provided that the conditions set out by the Compensation Fund are met.

If there is a possibility that an employee has been exposed to HIV during an occupational accident, the following steps should be taken:

• An accident report should be completed and forwarded to the Compensation Commissioner.

Details are as follows:
Compensation Commissioner   Telephone 012-319 9111
P O Box 955                                       Fax 012-326 7889
Pretoria 0001                                   www.wcomp.gov.za

• The employee concerned should be tested for HIV to determine their baseline status.
• Any person involved in the accident should be tested with informed consent.
• The employee, if HIV negative at the time of the accident, should be retested three and six months after the accident.

Standards of Behaviours and Grievance Procedures

To create an open, supportive and non-discriminatory working environment, the company will not permit any practice of discrimination, victimisation or intimidation against employees with HIV/AIDS.

All forms of such behaviour are deemed misconduct in the Company’s disciplinary code or code of conduct.

HIV/AIDS Programmes

To gain a better understanding and adequately address HIV/AIDS issues, the Company will assist in educating employees about the disease.
Aids Information

The National Aids Information Service number is 0800-112322

Various organisations, psychologists and social workers provide counselling services for Aids patients and their families.  Some of these are listed below:

• AIDS Action Group: Pastorie Building, Bellville, Ph 021 9487699
• AIDS Training and Information: Ph 021 797 3327
• AIDS Legal Networks: 114 Hout Street, Cape Town, Ph 021 423 9254
• AIDS Educational Group: (Planned Parenthood Organisation), Educational Unit 12, Anson Rd, Observatory, Ph 021 450 7312
• SACTWU Worker Health Program: Industria House, 350 Victoria Road, Salt River, Cape Town, Ph 021 – 448 5263.

2. Economy

Recruitment Policy

1. Creation and filling of posts

Before creating a post for any newly defined job or filling any vacancy, the CEO must:-

• confirm that the post is required to meet MWL objectives;
• in the case of a newly defined job, evaluate the job in terms of the job evaluation system;
• in the case of a vacant post, evaluate the job unless the specific job has been previously assessed; and
• ensure that sufficient budgeted funds, including funds for the remaining period of the medium-term expenditure framework, are available to fill the post.

2. Recruitment 

All recruitment and selection activities and decisions must be documented and filed for future reference.

All vacant and newly created positions will be advertised on the notice boards and circulated internally via email, where possible.  Where specific expertise and qualifications are required for a particular position, those positions will not need internal recruitment.

Should we not be able to find a suitable candidate from all the internal candidates, we will, at that point, advertise externally.

Preference will be given to permanent employees first and, after that, to contract employees. We will look externally to fulfil the role if we still have not found a suitable candidate.

All appointments will be subjected to the above recruitment process unless the appointment was made directly from the Bolton Head office.

1. Interviews

Potential candidates will be screened and short-listed by the HR department.  The respective department managers and HR managers will interview the shortlisted applicants.  Before the final appointment is made, the last two candidates will be interviewed by the CEO, who will make the final decision for approval of the candidate.
Psychometric testing will be done on all candidates who apply for a specialised or management-level position.

2. Appointments

All appointments are subject to a three-month probationary period.  In the case of contract appointments, the contract period will serve as the probationary period.

Training Policy

The project's objective is to develop and implement training programmes, over and above the regular training and development, at the various levels in the organisation to implement step changes to deliver the strategic Business objectives successfully.

Employees will have the opportunity to expand their knowledge and experience whilst striving for the company's competitive advantage.  In being selected for a MWL training programme, employees are in a perfect position to further their personal development.

However, training programmes in their magnitude and cost implications bring with them specific duties and responsibilities.

Duties and responsibilities of the candidate

• The candidate will attend all lectures, workshops, assessments, and meetings that form part of or are associated with the program.
• The candidate will study diligently and complete all assignments and tests to the best of their ability.
• The candidate authorises the company to have full access to study records and any evaluations done.
• The candidate must communicate with the company if they experience any problems or obstacles associated with the above or the course.
• The candidate realises that being selected or passing a course is no guarantee or fast track to a promotion, higher grade, or higher salary.
•  

Duties and responsibilities of the company

• The company will provide the candidate with adequate support, which might be in the form of a mentor.
• The company will cover the costs of the training as well as related costs, i.e. travel, accommodation, etc.
• The company will treat candidates' examination/evaluation results with the necessary confidentiality.

Commitment to the company in return for the study assistance granted
The candidate acknowledges that the company is assisting them with their studies on a personal basis and understands that the candidate agrees that they will work for the company for a minimum period of one(1) year after completing their training.

Provisions in the event of breach/failure

Suppose the student fails at any stage to comply with the above or fails the course. In that case, the company will be entitled, at its discretion, to refuse to make any further payments in respect of the course of studies undertaken by the student and to reclaim from the student the amount that has already been paid (either in whole or in part, the decision as to how much will be recycled to be in the sole discretion of the company).

Suppose the candidate resigns, or the candidate's services are terminated because of the candidate's misconduct or poor performance before having completed the minimum period of service referred to above. In that case, the company will be entitled to reimbursement of the monies paid by it under the terms of this arrangement on a pro-rata basis.

Example: If the candidate was required to work for a minimum of 12 months after completion of the course and resigns after six months, then the company will be entitled to reimbursement of 50% of the amount paid by it under the provisions of this agreement.

3. Environment 

We strive for transparency of our raw material sources and tannery operations to be held accountable for our pledge to lessen our environmental impact continuously.

Leather is sustainable when manufactured with a conscience. Leather ages better than any other material. If taken care of, leather is one of the most durable materials on earth. Its longevity results in a significantly decreased carbon footprint on the environment as the item made from it is used for longer, discouraging the fast consumer fashion “throw-away” mindset. Leather products tend to improve over time as the material ultimately reflects the user's lifestyle, developing a rich patina during everyday use. Buying leather from reputable tanners using responsible production processes will result in leather that biodegrades over time after use, alleviating landfill pressure. At Mossop, we look at the choices we make by continuously developing more sustainable ways of tanning our leather.

Chemical suppliers:

Our Chemical suppliers actively measure the impact of their product on the entire supply stream and ensure they comply with the EU-restricted substance list. They are also looking at carbon emissions and how they can reduce them to a minimum.

Our Effluent: 

Our effluent is treated to comply with the stringent requirements of our local municipality. We conduct weekly tests on our discharged effluent at an accredited laboratory to ensure full compliance with bylaws

Water-recycling:

Our WET-END WATER RECYCLING INNOVATION Our production's wet blue and rehydration stage sees us recycle 3,750 000 litres of water per year

Hides - Raw material 

Locally sourced hides: Over 70% of our rawhides locally give us real-time traceability into our primary raw material. 

Questions

If you have any questions about this policy or statements or their application to any situation, please get in touch with Human Resources.

ALL EMPLOYEES MUST READ AND UNDERSTAND THESE POLICIES